13 Dec 2018
Emma Radmore of Womble Bond Dickinson's Annual Update looks back at what has happened in the world of financial crime prevention since the 2017 update. It seems as if we are still coming to terms with the changes of 2017 yet now must adapt to more. And all this in the (at the time this article was written) uncertain climate as to when, or even whether, Brexit will happen and the terms on which any orderly or disorderly exist will take place. There have been some key developments on the EU front with the fifth Money Laundering Directive (MLD5) and the domestic front with the Sanction and Anti-Money Laundering Act 2018 (SAMLA). There are some key changes in the pipeline (reform of the Suspicious Activity Reports (SARs) regime, and in the mix the usual interesting enforcement actions and regulatory reviews.